After review of the draft, my only comment (other than the entire policy appears to be against the intent of Congress to hold an employer/employee relationship as the basis of the Act) is the Section (e) contractual control, (2) By a Combination of Other Rights has a somewhat confusing example.
It is unclear as to what is being explained using the example of multiple Primes and what appears to be no construction manager or overall general contractor. To clarify what appears to be the intent of the example, I suggest the following:

"A large project, with several prime contractors, with no Construction Manager (CM), contracted directly with the client purchasing construction services to build different phases of the job could each become controlling contractors for those employers subcontracted to the contractor in charge of steel erection coordinates their erection sequence with the prime in charge of concrete placement but has not specific rights to coordinate safety of the prime contractor placing the
concrete."

Other than the above comment, this is a major improvement over the existing guideline policy. Thank you for the opportunity to review and comment.

(Felipe, if you had been with us in Wakaiki we could have done this in a civilized manner - see you soon)

Thank You for Visiting Our Website

You are exiting the Department of Labor's Web server.

The Department of Labor does not endorse, takes no responsibility for, and exercises no control over the linked organization or its views, or contents, nor does it vouch for the accuracy or accessibility of the information contained on the destination server. The Department of Labor also cannot authorize the use of copyrighted materials contained in linked Web sites. Users must request such authorization from the sponsor of the linked Web site. Thank you for visiting our site. Please click the button below to continue.